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SEC imposes first FCPA-related administrative sanctions of individuals since 2012

The SEC reached an administrative settlement with two former employees of Oregon-based FLIR Systems, for their role in sending officials from the Saudi Arabian Ministry of Interior (“MOI”) on a trip to inspect products at FLIR’s Boston facility, which included stops in Casablanca, Paris, Dubai, Beirut and New York City, and for buying and giving five luxury watches totaling $7,000 to Saudi MOI officials, some of whom were also included in the trip. Timms, Exchange Act Release No. 73616 (Nov. 17, 2014). There were no allegations of cash payments. According to the SEC’s order, the travel and watches were offered in order to retain $12.9 million in business for thermal binoculars and to obtain a separate $17.4 million order for infrared security cameras. The SEC order further alleges that following an internal review by FLIR of Timms’ request for reimbursement for the cost of the watches, the former employees worked with a third-party agent to obtain false invoices understating the cost of the watches as 7,000 Saudi Riyal (approximately US $1,900), and inaccurately showing direct flights between Riyadh and Boston without the stopovers made by the MOI officials. Under the settlement, one former employee agreed to pay $50,000 and the other, $20,000, to resolve alleged violations of the FCPA’s anti-bribery and books-and-records provisions. This matter represents the SEC’s first administrative sanction of individuals since 2012.